OECD releases new documents on GloBE rules, jurisdiction status and the GloBE Information Return

On 15 January 2025, the Organisation for Economic Co-operation and Development (OECD) released technical documents on the operation of the Global Anti-Base Erosion (GloBE) Model Rules.

Key documents include new Administrative Guidance on the application of Article 9.1 (dealing with tax attributes upon transition), new Administrative Guidance on a Central Record of Legislation with Transitional Qualified Status, new Administrative Guidance on Article 8.1.4 and 8.1.5 (dealing with the GloBE Information Return), a Multilateral Competent Authority Agreement on the Exchange of GloBE Information and a User Guide for Tax Administrations on the GloBE Information Return (GIR) XML Schema. The documents contain significant additional information relevant to the interpretation and operation of the GloBE Rules, making them an essential component of the Global Minimum Tax package.

Specifically relevant for Belgium, the above mentioned new Central Record confirms that Belgium’s minimum tax legislation (see our Tax Alerts: Belgian parliament approves draft bill on Pillar Two and Belgian Pillar Two legislation further aligned with OECD’s guidance) completed the agreed process and secured transitional qualified status for the Qualified Income Inclusion Rules and the Qualified Domestic Minimum Top-up Tax Rules and QDMTT Safe Harbours.

For more information, please see our two EY Global Tax Alerts which you can access through the following links: OECD releases new documents on GloBE rules and on qualified jurisdiction status and OECD releases new documents on GloBE Information Return. 

In case you should have any questions regarding this matter, please do not hesitate to contact your trusted EY person of contact.